DCT

2:24-cv-00631

Helix Microinnovations LLC v. Micro Hybrid Electronic GmbH

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Key Events
Complaint

I. Executive Summary and Procedural Information

Case Timeline

Date Event
2002-02-26 U.S. Patent No. 7,238,550 Priority Date (Provisional App.)
2003-02-20 U.S. Patent No. 7,238,550 Application Filing Date
2007-07-03 U.S. Patent No. 7,238,550 Issue Date
2024-08-04 Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 7,238,550 - Methods and apparatus for fabricating Chip-on-Board modules, issued July 3, 2007

The Invention Explained

  • Problem Addressed: The patent describes an "ongoing need in the art for means and methods of producing low cost semiconductor devices," particularly a need to "make use of semiconductor devices that are partially-defective so that such device are not completely wasted" (’550 Patent, col. 2:13-18). Traditional manufacturing faced challenges with yield and cost, partly due to the difficulty of using these imperfect components.
  • The Patented Solution: The invention provides a method for fabricating Chip-on-Board (COB) memory modules by mounting unpackaged semiconductor die onto a printed circuit board (PCB) using "selectively settable liquids" (’550 Patent, col. 2:32-34). This method involves hardening a first ring of material around the die to hold it in place, then adding a second layer to "capture" the delicate bonding wires that connect the die to the PCB, which facilitates a more robust and repairable manufacturing process (’550 Patent, Fig. 1, steps 103, 104; col. 4:41-55).
  • Technical Importance: This approach allows manufacturers to effectively utilize lower-cost, "less-than-flawless" semiconductor die, thereby reducing production losses and the final cost of memory modules and other electronic components (’550 Patent, col. 3:49-54).

Key Claims at a Glance

  • The complaint does not specify which claims are asserted, referring only to "Exemplary '550 Patent Claims" (Compl. ¶11). Independent claim 1 is a representative method claim.
  • Independent Claim 1: A method of fabricating Chip-on-Board logic modules, with the key steps comprising:
    • mounting unpackaged die using a first layer of selectively-settable material;
    • hardening a ring of said first layer of selectively-settable material around a periphery said unpackaged die;
    • covering said first layer of selectively-settable material with a second layer of selectively-settable material; and
    • capturing bonding wires connecting said unpackaged die to a printed circuit board in said second layer of selectively-settable material.
  • The complaint does not explicitly reserve the right to assert other claims, but its general allegations suggest this possibility.

III. The Accused Instrumentality

Product Identification

  • The complaint does not identify any specific accused products by name. It refers generally to "Exemplary Defendant Products" that are purportedly identified in "charts incorporated into this Count" (Compl. ¶11).

Functionality and Market Context

  • The complaint states that these charts are included in Exhibit 2 (Compl. ¶13). As Exhibit 2 was not provided with the complaint, no description of the accused instrumentality’s functionality, features, or market context can be derived from the pleading.

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are made by incorporating by reference "the claim charts of Exhibit 2" (Compl. ¶14). Because Exhibit 2 is not part of the public record, the specific theory of infringement—how the accused products allegedly meet each element of the asserted claims—is not detailed in the complaint. The pleading asserts in a conclusory manner that the "Exemplary Defendant Products practice the technology claimed by the '550 Patent" (Compl. ¶13). No probative visual evidence provided in complaint.

Identified Points of Contention

  • Given the lack of specific allegations, any analysis must be predictive. Based on the language of claim 1 of the ’550 Patent, litigation will likely focus on several key technical and scope questions:
    • Technical Questions:
      • Does the Defendant's manufacturing process for its modules utilize a material that meets the definition of a "selectively-settable material" as contemplated by the patent?
      • Does the Defendant's process involve "capturing bonding wires" in a second layer of material, and if so, does the mechanism of that capture correspond to the process described in the patent (e.g., placing wires within a still-manageable liquid which is then hardened)? (’550 Patent, col. 4:47-50).
    • Scope Questions:
      • How broadly can the term "unpackaged die" be interpreted, and do the components used by the Defendant fall within that scope?
      • What is the scope of "capturing bonding wires"? Does it require physically embedding the wires as shown in the patent's embodiments (e.g., Fig. 4b), or could it be read more broadly to cover other forms of wire protection or stabilization?

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of specific claim construction disputes. However, based on the language of independent claim 1, the following terms are likely to be central.

  • The Term: "selectively-settable material"

  • Context and Importance: This term is the foundational element of the claimed method. Its definition will determine what types of manufacturing processes fall within the patent's scope. Practitioners may focus on this term because its breadth is a primary question for infringement.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent repeatedly uses the general term "selectively settable liquids" without limitation, suggesting the term is not confined to a single type of substance (’550 Patent, col. 2:34).
    • Evidence for a Narrower Interpretation: The specification provides specific examples, stating the materials "comprise UV-settable materials" (’550 Patent, col. 11:10) and referencing "adhesives made by Dymax Corporation" (’550 Patent, col. 3:64-65). A defendant might argue these examples limit the term to light-curable adhesives.

  • The Term: "capturing bonding wires"

  • Context and Importance: This active step is a critical limitation differentiating the invention from prior art methods of simply covering or encapsulating a chip. The precise meaning of "capturing" will be a key point of dispute.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The claim language itself does not specify the exact mechanism of "capturing," potentially allowing for a range of methods that secure the wires.
    • Evidence for a Narrower Interpretation: The specification describes a specific sequence where "wires may be captured by carefully placing the wires within the second ring while the selectively settable material is still manageable and then hardening the ring" (’550 Patent, col. 4:47-50). Figure 4b visually depicts this, showing wires (415) physically embedded within a second material layer (416). A defendant could argue this limits "capturing" to this specific embedding process.

VI. Other Allegations

  • Indirect Infringement: The complaint makes no allegations of indirect infringement (inducement or contributory infringement). The allegations are limited to direct infringement by Defendant and its employees (Compl. ¶11, ¶12).
  • Willful Infringement: The complaint does not contain factual allegations typically used to support a claim for willful infringement, such as pre-suit knowledge of the patent. However, the prayer for relief requests a judgment that "this case be declared exceptional within the meaning of 35 U.S.C. § 285" and that attorneys' fees be awarded (Compl. ¶E.i).

VII. Analyst’s Conclusion: Key Questions for the Case

The complaint, as filed, presents a "notice pleading" that leaves the core of the dispute undefined. The case will likely turn on the following high-level questions:

  1. An Evidentiary Question of Fact: The primary hurdle will be establishing the facts of the accused process. As the complaint provides no details regarding the "Exemplary Defendant Products," the initial phase of the case will revolve around discovering what manufacturing process Defendant actually uses and whether it aligns with the patent’s claims.
  2. A Definitional Question of Scope: Assuming the facts are established, the case will hinge on claim construction. A central issue will be whether the term "selectively-settable material", as used in the patent, is broad enough to read on the materials used in Defendant’s process, or if it is limited to the specific UV-curable adhesives described in the embodiments.
  3. A Functional Question of Infringement: A key battleground will be whether Defendant’s method of securing bonding wires performs the function of "capturing" them as required by claim 1. The court will have to determine if this requires the specific physical embedding shown in the patent or if other methods of securing wires meet the claim limitation.